last antecedent rule (Missouri) · Go Syfert
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last antecedent rule in Missouri

17 Missouri opinions name it 3 courts 1973–2022 2 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Rothschild v. State Tax Com'n of Missourigreen
mo · 1988 · cited in 4 Missouri opinions naming this issue, 1992–2016
2 sentences

2016The phrase “which occurred while in office” modifies the noun “felony’ rather than the more remote verb “is convicted.” Under the last antecedent rule, “ ‘relative and qualifying words, phrases, or clauses are to be applied to the words or phrase immediately preceding and are not to be construed as extending to or including others more remote.’ ” Wyman v. Mo. Dept. of Mental Health, 376 S.W.3d 16 , 21 n. 7 (Mo.App.W.D.2012) (quoting Rothschild v. State Tax Comm’n, 762 S.W.2d 35, 37 (Mo.banc 1988)).

2016The phrase “which occurred while 4 in office” modifies the noun “felony” rather than the more remote verb “is convicted.” Under the last antecedent rule, “‘relative and qualifying words, phrases, or clauses are to be applied to the words or phrase immediately preceding and are not to be construed as extending to or including others more remote.’” Wyman v. Mo. Dept. of Mental Health, 376 S.W.3d 16 , 21 n.7 (Mo. App. W.D. 2012)(quoting Rothschild v. State Tax Comm’n, 762 S.W.2d 35, 37 (Mo. banc 1988)).

44
Spradling v. SSM Health Care St. Louisgreen
mo · 2010 · cited in 4 Missouri opinions naming this issue, 2017–2022
2 sentences

2022Louis, 313 S.W.3d 683, 688 (Mo. banc 2010)) (explaining that “relative and qualitative words are to be applied only to the words or phrases preceding them[,]” 22 consistent with the last antecedent doctrine).

2021Louis, 313 S.W.3d 683, 688 (Mo. banc 2010) (citation omitted).

34
Elliott v. James Patrick Hauling, Inc.green
moctapp · 1973 · cited in 3 Missouri opinions naming this issue, 1990–2016
2 sentences

2016Elliott, 490 S.W.2d at 287 . (internal quotation marks omitted). "[T]he safest and surest test to determine whether the general rule of the last antecedent or the exception thereto is to be applied is . . . (a) common-sense interpretation . . . bearing always in mind the mischiefs to be remedied and the benefits to be secured by the law." Id. (internal quotation marks omitted).

2016Elliott, 490 S.W.2d at 287 . (internal quotation marks omitted). "[T]he safest and surest test to determine whether the general rule of the last antecedent or the exception thereto is to be applied is . . . (a) common-sense interpretation . . . bearing always in mind the mischiefs to be remedied and the benefits to be secured by the law." Id. (internal quotation marks omitted).

13
Blue Cross & Blue Shield of Kansas City, Inc. v. Nixongreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2017–2017
1 sentence

2017"The best and surest test to determine whether the general rule of the last antecedent or the exception thereto is to be applied is a 'common sense interpretation.’ ” Blue Cross & Blue Shield of Kansas City v. Nixon, 26 S.W.3d 218, 234 (Mo.App.

11
Boatmen's Trust Co. v. Sugdengreen
moctapp · 1992 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010See e.g., Boatmen's Trust Co. v. Sugden, 827 S.W.2d 249 (Mo.App.

11
Kahn Lucas Lancaster, Inc. v. Lark International Ltd.green
ca2 · 1999 · cited in 1 Missouri opinions naming this issue, 2003–2003
2 sentences

2003No doubt it is possible, under the last antecedent rule, see Kahn Lucas Lancaster, Inc. v. Lark Int’l Ltd., 186 F.3d 210, 215-16 (2nd Cir.1999), that the prepositional phrase only applies to personal immunity.

2003No doubt it is possible, under the last antecedent rule, see Kahn Lucas Lancaster, Inc. v. Lark Int'l Ltd., 186 F.3d 210, 215-16 (2nd Cir.1999), that the prepositional phrase only applies to personal immunity.

11
Wilkinson v. Brunegreen
moctapp · 1984 · cited in 1 Missouri opinions naming this issue, 1992–1992
1 sentence

1992We have long adhered to the well established rule of ejusdem generis as a tool of statutory construction. “... [W]here general words follow a specific enumeration of persons or things, the general words should be limited to persons or things similar to those specifically enumerated.” Pollard v. Board of Police Com’rs, 665 5.W.2d 333, 341 (Mo banc 1984) [citation omitted]; Wilkinson v. Brune, 682 S.W.2d 107, 111 (Mo.App.1984) (“In construing a statute, [courts] must give effect to the expressed intent of the legislature, [courts] must not add provisions under the guise of construction if they a

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Nordberg v. Montgomery green
· 1943
2 sentences

2010Norberg’s holding illustrates a scenario in which the Missouri Supreme Court decided not to utilize the last antecedent rule of statutory construction. 173 S.W.2d at 390-91 .

1990It has not been ". . . adhered to where extension to a more remote antecedent is clearly required by consideration of the entire act." Norberg v. Montgomery, 351 Mo. 180 , 173 S.W.2d 387 , 390 (Mo. banc 1943). "[T]he `safest and surest' test to determine whether the general rule of the last antecedent or the exception thereto is to be applied is `. . . [a] common-sense interpretation . . . bearing always in mind the mischiefs to be remedied and the benefits to be secured by the law." Elliott v. James Patrick Hauling, Incorporated, supra, 490 S.W.2d at 287 , quoting State ex rel.

31990–2010
Wyman v. Missouri Department of Mental Health green
moctapp · 2012
2 sentences

2016The phrase “which occurred while in office” modifies the noun “felony’ rather than the more remote verb “is convicted.” Under the last antecedent rule, “ ‘relative and qualifying words, phrases, or clauses are to be applied to the words or phrase immediately preceding and are not to be construed as extending to or including others more remote.’ ” Wyman v. Mo. Dept. of Mental Health, 376 S.W.3d 16 , 21 n. 7 (Mo.App.W.D.2012) (quoting Rothschild v. State Tax Comm’n, 762 S.W.2d 35, 37 (Mo.banc 1988)).

2016The phrase “which occurred while 4 in office” modifies the noun “felony” rather than the more remote verb “is convicted.” Under the last antecedent rule, “‘relative and qualifying words, phrases, or clauses are to be applied to the words or phrase immediately preceding and are not to be construed as extending to or including others more remote.’” Wyman v. Mo. Dept. of Mental Health, 376 S.W.3d 16 , 21 n.7 (Mo. App. W.D. 2012)(quoting Rothschild v. State Tax Comm’n, 762 S.W.2d 35, 37 (Mo. banc 1988)).

22016–2016
Missouri Highway & Transportation Commission v. Kansas City Cold Storage, Inc. green
moctapp · 1997
1 sentence

2012The fact that § 537.600 addresses only those claims which seek to impose monetary liability on the State is confirmed by Missouri Highway and Transportation Commission v. Kansas City Cold Storage, Inc., 948 S.W.2d 679 (Mo.App.

12012–2012
Union Electric Co. v. Director of Revenue green
mo · 1990
1 sentence

1995Union Electric Company v. Director of Revenue , 799 S.W.2d 78 , 79 (Mo. banc 1990).

11995–1995
State ex rel. Crow v. City of St. Louis green
· 1903
1 sentence

1973But the “safest and surest” test to determine whether the general rule of the last antecedent or the exception thereto is to be applied is “. . . fa] common-sense interpretation bearing always in mind the mischiefs to be remedied and the benefits to be secured by the law.” Crow, supra, 73 S.W. at 629 .

11973–1973

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 538.225 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 72 (1941–2026) IL 64 (1977–2024) TX 60 (1979–2025) CA 53 (1991–2024) MI 38 (1975–2026) FL 29 (1981–2024) OR 18 (1996–2024) MO 17 (1973–2022) AZ 16 (1984–2025) PA 15 (1974–2026) NM 11 (1996–2022) NC 10 (1990–2026) CO 10 (1989–2026) MA 9 (1940–2025) SD 8 (1990–2011) WI 7 (1915–2021) OK 7 (1994–2025) CT 7 (1996–2019) KS 6 (1989–2022) ID 5 (1994–2026) NY 5 (1931–2018) OH 5 (2011–2024) VA 5 (2004–2023) NH 4 (2010–2025) MD 4 (2014–2026) NJ 3 (2017–2021) AK 3 (1983–2010) NV 3 (2011–2015) MN 3 (2016–2019) IA 3 (2006–2016) RI 2 (1985–2013) DE 2 (2016–2021) ND 2 (2019–2023) IN 2 (2008–2016) VT 2 (2010–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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